The deadlines
Two obligations run independently of each other: the obligation to receive and the obligation to issue. The obligation to receive is the more inconvenient one, because it applies without a transitional period and has already been in effect since 1 January 2025.
The threshold of €800,000 is set out in Section 27(38) UStG. It refers to the total turnover within the meaning of Section 19(2) UStG of the preceding calendar year. For the obligation from 1 January 2027, the calendar year 2026 therefore counts. Anyone just below the threshold gains exactly one year for supplies in 2027.
Important for the receiving side: the BMF clarifies that a business that cannot receive technically or refuses to accept an e-invoice has no right to a paper invoice. The issuer has fulfilled its obligations if it has issued the e-invoice and can prove that it made an effort to transmit it, for example via a transmission log.
Exceptions
Three groups of cases may permanently be issued and transmitted as other invoices. The BMF letter names them expressly and refers to the German VAT Implementing Ordinance (UStDV):
- Small-value invoices up to a total amount of €250 (Section 33 UStDV)
- Tickets for the transport of passengers (Section 34 UStDV)
- Invoices from small businesses under the special scheme of Section 19 UStG (Section 34a UStDV)
Beware of the symmetry: the exception only concerns issuing. A small business may continue to write paper invoices but must still be able to receive e-invoices. This asymmetry surprises almost everyone affected in advisory meetings.
Cases without a VAT obligation to issue an invoice are not covered at all: invoices to end consumers (B2C) and supplies that are exempt from VAT under Section 4 nos. 8 to 29 UStG, such as VAT-exempt financial services or the letting of land and buildings (Section 14(2), sentence 2 UStG, BMF FAQ, question 4, in German). 1 January 2028 does not change this either.
Outside the exceptions, the obligation applies broadly. It also covers credit notes issued by the recipient (self-billing), supplies subject to the reverse charge under Section 13b UStG and cases in which the recipient is a small business or exclusively makes VAT-exempt supplies, such as a residential landlord.
Transmission: no central portal, no requirement
Germany has deliberately decided against a state platform. According to the BMF, permitted methods include email, download via an internet portal, EDI, provision via an electronic interface and shared access to a central storage location.
Which route and which format the parties agree on is expressly a matter of civil law, not of VAT law. For receipt by email, no separate mailbox exclusively for e-invoices is required. This removes unnecessary complexity from many projects.
In larger supply chains, Peppol is gaining ground as a transport network because it standardises addressing and delivery. It is not mandatory. For an SME with thirty invoice customers, email plus validation is usually the cheaper and more robust solution.
Archiving and GoBD
Under Section 14b(1) UStG, you keep a copy of every incoming and outgoing invoice for eight years. The period begins at the end of the calendar year in which the invoice was issued. For an e-invoice, at least the structured part must be kept intact in its original form.
The BMF letter nevertheless contains some reassurance. Storage outside a GoBD-compliant data processing system alone does not generally constitute a breach of Section 14b(1) UStG for VAT purposes. For other tax purposes, the letter refers to the GoBD principles (the German principles for the proper keeping of books and records in electronic form) as amended from time to time.
Implementation in ERP and online shop
Technically, the e-invoice is not a major project, but organisationally it is. The effort rarely lies in generating the XML, but in the master data. Missing routing IDs (Leitweg-IDs), incomplete buyer references and inconsistent tax rate codes are the most common blockers.
The BMF distinguishes between two classes of errors, and the difference is relevant in practice. A format error means that the file does not meet the requirements of Section 14(1), sentence 6 UStG. In that case, there is simply no e-invoice. A business rule error, on the other hand, is a breach of the format’s validation rules, for example a missing mandatory field “BT-10 Buyer reference”.
This leads to a clear recommendation: validate every outgoing e-invoice automatically before sending it. The BMF expressly refers to suitable validation applications. A validator in the outgoing process costs a few person-days and prevents invoice runs that come back one after another.
In interaction with the ERP system, there are two patterns. Either the ERP generates and reads the formats itself, which is increasingly the case with current standard software. Or a converter sits in front of it as middleware, which is the more pragmatic route for legacy systems and organically grown landscapes.
For online shops, invoice dispatch is an additional factor. If you sell B2B, the invoice must go out as an e-invoice from the respective obligation stage, not as a PDF in the order confirmation email. Because incoming invoices also arrive in structured form, process automation of invoice verification usually pays off here at the same time.
Real-world example: the federal government has required XRechnung since 2020
Anyone who thinks this is new has missed the B2G side. Under Section 3(1) of the E-Invoicing Ordinance (ERechV), invoice issuers must invoice federal authorities electronically. This obligation came into force on 27 November 2020; essentially only direct orders up to €1,000 are exempt.
Example scenario: wholesaler with federal customers
Suppose a wholesaler has been supplying federal institutions for years and already issues XRechnungen for this via an administration portal. For the B2B obligation from 1 January 2027, the format would then essentially be solved.
In this scenario, the incoming side would remain open. If supplier invoices have so far arrived as PDFs and are printed, signed off and scanned, exactly this process breaks as soon as suppliers deliver structured data. The redesign would then concern not invoicing but accounts payable.
The lesson from this scenario generalises well. Those who already invoice B2G usually have the outgoing side under control and underestimate the incoming side. Those who have never seen an XRechnung usually underestimate the master data work.
Outlook: ViDA
At EU level, the “VAT in the Digital Age” (ViDA) reform is under way. As things stand, the Council adopted the package in March 2025; mandatory electronic invoicing with digital reporting for intra-Community B2B supplies is planned for July 2030.
For planning, this means one thing above all: the German obligation is not an isolated solution that can be sat out with a makeshift transitional fix. Anyone who switches to structured formats in 2026 or 2027 is laying the foundation for the EU step at the same time. As long as national implementation is not available, details remain open.
Frequently asked questions
Is a PDF sent by email an e-invoice?
No. Under Section 14(1), sentence 4 UStG, a PDF is an other invoice in an electronic format. It lacks the structured, machine-processable data record. Only as a PDF/A-3 with embedded XML according to ZUGFeRD from version 2.0.1 (without the MINIMUM and BASIC-WL profiles) does it become an e-invoice.
Do I need the recipient’s consent?
Not for an e-invoice to another domestic business. The BMF letter expressly clarifies that issuing it does not require consent. Consent is required in the reverse case: an other invoice in another electronic format, typically the PDF.
Does the obligation also apply to private customers?
No. The obligation under Section 14(2), sentence 2, no. 1 UStG concerns supplies to another business for its business, if both are established in Germany. In B2C business, nothing changes. A shop with a mixed customer base therefore needs two invoicing routes.
Is it enough to print out the XML file as a PDF and file it?
No. At least the structured part must be kept, intact in its original form, for eight years. A printout or a rendered image does not meet this requirement, because machine processability is lost.
What happens if an incoming e-invoice contains errors?
That depends on the error. In the case of a format error, there is no e-invoice but an other invoice. If there is an obligation to issue an e-invoice, you can demand a proper e-invoice from the issuer. The input VAT deduction is not automatically lost as a result: if the invoice is correct and complete in terms of content, the BMF takes the view that the conditions for it are generally met.
If, on the other hand, mandatory details under Sections 14 and 14a UStG are missing, the invoice is not compliant. If you cannot prove the conditions for input VAT deduction in another way, the issuer must correct it. Business rule errors concerning other content, such as an empty field “BT-10 Buyer reference”, are irrelevant for VAT purposes. A validation application detects format and business rule errors, but not every content error, for example not an incorrect tax rate.
